Information series 12: environmental management plans

Integrated Environmental Management Information Series

12EnvironmentalManagement Plans

Department ofEnvironmental Affairs and Tourism

Other topics in the series of overview information documents on the concepts of, and approaches to, integrated environmentalmanagement are listed below. Further titles in this series are being prepared and will be made available periodically. Sequenceof release and titles are subject to change.

Information Series 0:Information Series 1:Information Series 2:Information Series 3:Information Series 4:Information Series 5:Information Series 6:Information Series 7:Information Series 8:Information Series 9:Information Series 10:Information Series 11:Information Series 12:Information Series 13:Information Series 14:Information Series 15:Information Series 16:

ISSUED BY

Department of Environmental Affairs and TourismPrivate Bag X447Pretoria0001 South Africa

This document is available on the DEAT web site: http://www.deat.gov.za

PLEASE NOTE: This document is intended as an information source and cannot take the place of legal advice in a specific situationgoverned by legislation. The document is not a guideline document, but serves as a reference and supportive text. This document willnot take the place of official guidelines and regulations published by DEAT.

COPYRIGHT © Department of Environmental Affairs and Tourism 2004. ALL RIGHTS RESERVED

This document is copyright under the Berne Convention. Apart from the purpose of private study, research or teaching, in terms ofthe Copyright Act (Act No. 98 of 1978) no part of this document may be reproduced or transmitted in any form or by any means,electronic or mechanical, including photocopying, recording or by any information storage and retrieval system, without permissionin writing from DEAT. Likewise, it may not be lent, resold, hired out or otherwise disposed of by way of trade in any form of bindingor cover other than that in which it is published.

ENQUIRIES AND COMMENTS

All enquiries and comments should be addressed to:The Director: Environmental Impact ManagementDepartment of Environmental Affairs and TourismPrivate Bag X447Pretoria0001 South Africa

REFERENCING

When referencing this document, it should be cited as follows:DEAT (2004) Environmental Management Plans, Integrated Environmental Management, Information Series 12, Department of EnvironmentalAffairs and Tourism (DEAT), Pretoria.

ISBN 0-9584728-3-1

PREFACE

This document is one of a series of overview information documents on the concepts of, and approaches to, IntegratedEnvironmental Management (IEM). IEM is a key instrument of South Africa’s National Environmental Management Act(NEMA). South Africa’s NEMA promotes the integrated environmental management of activities that may have a significanteffect (positive and negative) on the environment. IEM provides the overarching framework for the integration ofenvironmental assessment and management principles into environmental decision-making. It includes the use of severalenvironmental assessment and management tools that are appropriate for the various levels of decision-making.

The aim of this document series is to provide general information on techniques, tools and processes for environmentalassessment and management. The material in this document draws upon experience and knowledge from South African

Overview of Integrated Environmental ManagementScreeningScopingStakeholder EngagementSpecialist StudiesImpact SignificanceEcological Risk AssessmentCumulative Effects AssessmentCost Benefit AnalysisLife Cycle AssessmentStrategic Environmental AssessmentCriteria for determining Alternatives in EIAEnvironmental Management PlansReview in Environmental Impact AssessmentEnvironmental AuditingEnvironmental Impact ReportingEnvironmental Economics

page 1

Environmental Management Plans

page 2

practitioners and authorities, and published literature on international best practice. This document is aimed at a broadreadership, which includes government authorities (who are responsible for reviewing and commenting on environmentalreports and interacting in environmental processes), environmental professionals (who undertake or are involved inenvironmental assessments as part of their professional practice), academics (who are interested in and active in theenvironmental assessment field from a research, teaching and training perspective), non-government organisations(NGOs) and interested persons. It is hoped that this document will also be of interest to practitioners, governmentauthorities and academics from around the world.

This document has been designed for use in South Africa and it cannot reflect all the specific requirements, practiceand procedures of environmental assessment in other countries.

This series of documents is not meant to encompass every possible concept, consideration, issue or process in the rangeof environmental assessment and management tools. Proper use of this series of documents is as a generic reference,with the understanding that it will be revised and supplemented by detailed guideline documents.

The opinions expressed and conclusions drawn are those of the author’s and are not necessarily the official view of thepublisher, the Department of Environmental Affairs and Tourism. The author and publisher make no representation orwarranty, expressed or implied, as to the completeness, correctness or utility of the information in this publication.Whilst every effort has been made to ensure that the information contained herein is accurate, the author and publisherassume no liability of any kind whatsoever resulting from the use or reliance upon the contents of this publication.

ACKNOWLEDGEMENTS

NoteAll sources used have been acknowledged by means of complete references.

Principal Authors Andrew Spinks and Kamal Govender (Ninham Shand)

Project Co-ordinators Anben Pillay (DEAT) and Nigel Rossouw (CSIR)

Editorial Review Pat Morant, Nigel Rossouw (CSIR) and Anben Pillay (DEAT)

Peer Review Andrew Duthie (Oryx Environmental)

Paul Lochner (CSIR)

Departmental Review Mark Gordon (DEAT)

SUMMARY

Most of the global environmental assessment practiceappears to be directed at the scoping and assessmentstages of the Environmental Impact Assessment (EIA)process. The mitigation, monitoring and managementcomponent of EIAs receive less attention. Attention is nowbeing focused on the need to demonstrate that impactscan be monitored and managed. The EnvironmentalManagement Plan (EMP) is recognised as the tool that canprovide the assurance that the project proponent hasmade suitable provisions for mitigation. The EMP is thedocument that provides a description of the methods andprocedures for mitigating and monitoring impacts. TheEMP also contains environmental objectives and targetswhich the project proponent or developer needs to achievein order to reduce or eliminate negative impacts. TheEMP document can be used throughout the project lifecycle. It is regularly updated to be aligned with the projectprogress from construction, operation to decommissioning.EMPs provide a link between the impacts predicted andmitigation measures specified within the EIA report, andthe implementation and operational activities of theproject. EMPs outline the environmental impacts, themitigation measures, roles and responsibilities, timescalesand cost of mitigation.

Three broad categories of EMPs can be recognised in theproject lifecycle. They are the construction phase EMP,the operational phase EMP and the decommissioning phase

EMP. The objectives of these EMPs are all the same, namelyto:* identify the possible environmental impacts of the

proposed activity; and* develop measures to minimise, mitigate and manage

these impacts.

The difference between these EMPs is related to thedifference in mitigation actions required for the differentstages of the project cycle.

The development and implementation of a successful EMPhas benefits beyond merely meeting legal obligations. Itcontributes to environmental awareness of the workforce.It can facilitate the prevention of environmentaldegradation, and minimise impacts when they areunavoidable. Given the current focus on the assessmentstage of EIA, EMPs add value to decision-making bydemonstrating commitment to implementation of mitigationactions. The EMP facilitates progress towards environmentaltargets and provides a tool for continual improvement ofa company’s environmental performance.

page 3


CONTENTSSummary

Contents

1. INTRODUCTION

2. PURPOSE OF THIS DOCUMENT

3. ENVIRONMENTAL MANAGEMENT THROUGHOUT THE PROJECT LIFE CYCLE

4. ENVIRONMENTAL MANAGEMENT PLANS

5. LEGAL ENFORCEABILITY OF ENVIRONMENTAL MANAGEMENT PLANS

6. TYPES OF ENVIRONMENTAL MANAGEMENT PLANS

6.1 The Construction Phase Environmental Management Plan6.2 The Operational Phase Environmental Management Plan6.3 The Decommissioning Phase Environmental Management Plan

7. STATEGIC ENVIRONMENTAL MANAGEMENT PLANS

8. INTEGRATION OF THE EMP INTO OPERATIONS

9. IMPLEMENTATION AND MONITORING

9.1 Developing a Monitoring Plan9.2 Monitoring and Data Collection9.3 The Environmental Awareness Training9.4 Audits

10. PUBLIC INVOLVEMENT

11. CONCLUSIONS

12. REFERENCES

13. GLOSSARY

TABLES

Table 1: Example of a format for data collection and monitoring

FIGURES

Figure 1: Illustration of the hierarchical link between an Environmental Management System (EMS) (for an organisation),the Environmental Management Programme (which fits within the EMS) and the Environmental Management Plan (whichfits within the Environmental Management Programme) (Source: Lochner and Rossouw, in litt., 2004)

Figure 2: Hierarchy of environmental systems, showing the conceptual relationship between SEA; a StrategicEnvironmental Management Plan (SEMP); and Environmental Management Systems (adapted from CSIR, 1997)

Figure 3: Framework process for developing the EMP and monitoring programme (adapted from EPA, 1995b)

2

3

4

4

4

6

7

7

777

8

9

9

9101111

11

11

11

13

10

5

8

9

page 4

1. INTRODUCTION

Since the 1970s, the approach to integrated environmentalmanagement (IEM) in South Africa has undergone significantchanges (Mafune et al., 1997). From modest beginningsas a voluntary process, IEM in South Africa reached amilestone in 1997 with Environmental Impact Assessment(EIA) becoming mandatory. Despite IEM beingconceptualised as a toolbox and promoting the conceptof “cradle-to-grave” environmental management (DEAT,2004a), EIA received greater attention than the othertools. Since EIAs became a regulated process in SouthAfrica in 1997, most of the effort was directed at thescoping and assessment stages of the EIA process. Themitigation, monitoring and management component ofEIAs received much less attention.

Attention is now being focused on the need to demonstratethat impacts can be monitored and managed. TheEnvironmental Management Plan (EMP) is recognised asthe tool that can provide the assurance that the projectproponent has made suitable provision for mitigation.

The EMP provides a description of the methods andprocedures for mitigating and monitoring impacts. TheEMP also contains environmental objectives and targetswhich the project proponent or developer needs to achievein order to reduce or eliminate negative impacts. TheEMP document can be used throughout the project lifecycle. It should be regularly updated to remain alignedwith the project as it progresses from construction tooperation and, finally to decommissioning. Developingcountries have been slow to use and implement EMPs(George, 2000). Ira et al. (2000) and Parkes et al. (2001),attribute the slow utilisation of EMPs to the following:

* EIA policy systems generally focus on the assessmentpart of the process;

* the lack of guidelines for the compilation and implementation of EMPs;

* the lack of legal enforcement of EMPs;* the failure of EMPs to take account of the financial

implications of environmental controls; and* governments not focusing on and building the

institutional capacity for monitoring and enforcing compliance.

However, there is now a growing recognition that EMPscan be effective environmental management tools bylinking their implementation to project authorisation.

2. PURPOSE OF THIS DOCUMENT

This document serves as an initial reference text for abroad readership, including government authorities,environmental professionals, academics, and NGOs. Itaims to provide a generic introductory information sourceon the purpose, objectives and content of EMPs.

3. ENVIRONMENTAL MANAGEMENT THROUGHOUT THE PROJECT LIFE CYCLE

Integrated Environmental Management (IEM) is a continuousprocess that ensures that environmental impacts areavoided or mitigated throughout the project life cycle

from design, to implementation, operation anddecommissioning (DEAT,2004a). After the feasibility anddesign stage of a project, the project proposal is usuallysubjected to an EIA. The resultant EIA report normallyspecifies mitigation and management actions.

One of the IEM tools that practitioners use for managingenvironmental impacts at the project implementationstage is the Environmental Management System (EMS).EMS provides a systematic framework and approach tominimise risks and control environmental aspects (i.e.activities that cause impacts) and impacts (i.e. effect orchange to the environment resulting from an activity).EMS is a cyclical process aimed at assisting an organisationto achieve continuous improvement in environmentalperformance (EPA, 1995a).

Companies use the EMS framework to achieve continuousimprovement in environmental performance. TheInternational Standards Organization has issued theinternational standard ISO 14001, to provide an agreeddefinition of a sound EMS (George, 2000). ISO 14001 isone of a series of environmental standards, covering areassuch as the environmental management of operations.Among the series of standards, ISO 14004 (general guidelineson EMS), ISO 14010 (principles of auditing), ISO 14011(audit procedures for EMS) and ISO 14012 (auditorqualifications) provide guidance and support for theenvironmental management systems framework describedin the ISO 14001 document (DEAT, 2004b).

As well as defining what constitutes a sound EMS, ISO14001 makes it possible for operators to obtain independentcertification to prove that their environmental managementsystem meets the requirements of the standard (George,2000).

According to George (2000) the basic elements of an EMScomplying with ISO 14001 are:

* a list of potential environmental impacts;* a set of operational procedures for monitoring,

controlling and reducing impacts, and recording the results; and

* a procedure for internal audits of the procedures.

An important feature of ISO 14001 is its requirement thatimpacts should not only be controlled, but reduced, withspecific targets and action plans defined by the operator(George, 2000). The components of an EMS consist ofpolicy, planning, operational procedures, checking andreview. In the implementation of projects there is thetendency to refer to an Environmental ManagementProgramme, which provides the overall framework forenvironmental management. In the implementation oflarge, complex projects EMPs fit within the overallEnvironmental Management Programme. EMPs may beprepared for specific areas or management functions suchas solid waste management. Figure 1 provides an illustrationof the link between Environmental Management Systems,Environmental Management Programmes and EnvironmentalManagement Plans. Figure 1 provides a conceptualframework for the location and function of EMPs for

page 5


complex projects such as aluminium smelters, petro-chemical plants and large mining operations. It isacknowledged that in practice and where EMPs are usedmay differ from the way Figure 1 illustrates the concept.The context and the need will determine whetherEnvironmental Management Programmes or EMPs aredeveloped. In practice EMPs may be consolidated into anintegrated document, describing all facets of thedevelopment activities. In Figure 1, EMPs are illustratedas being prepared for isolated and distinct functions.

For small to medium sized projects of the type which areimplemented frequently and where the impacts are knownand the mitigation measures are standard, EMPs for

construction are the most appropriate tool. Genericconstruction EMPs can be developed for projects such asroad infrastructure, electrical powerlines, petrol fillingstations, golf courses and cellular phone infrastructure.These small projects normally have standard constructionand implementation specifications. Standard EMP formats,therefore, can be applied to them.

EMPs provide a link between the impacts predicted andmitigation measures specified within the EIA report, andthe implementation and operational activities of theproject. EMPs outline the environmental impacts, themitigation measures, roles and responsibilities, timescalesand cost of mitigation (World Bank, 1999).

Figure 1: Illustration of the hierarchical link between an Environmental Management System (EMS) (for anorganisation), the Environmental Management Programme (which fits within the EMS) and the EnvironmentalManagement Plan (which fits within the Environmental Management Programme) (Source: Lochner and Rossouw,in litt., 2004)

Company level EMSmodel (based on theISO 14001 standard)

Implementation of alarge and complex

project

ManagementReview

Checking

* Measurement* Monitoring* Audits* Corrective

action

ContinuousImprovement

Implementationand Operation

* Responsibility* Training* Document

Control* Emergency

Responce

Planning

* Environmental Aspects

* Objectives and Targets

* Environmental Management Programmes

EnvironmentalPolicy

Construction Operation Decommissioning

EnvironmentalManagementProgramme



EnvironmentalManagement Plan:

Solid WasteManagement

EnvironmentalManagement Plan:

Waste WaterManagement

page 6

4. ENVIRONMENTAL MANAGEMENT PLANS

There is no universally accepted standard format for EMPs.The format needs to fit the circumstances in which theEMP is being developed and the requirements which it isdesigned to meet (World Bank, 1999). According to theWorld Bank (1999) EMPs should contain the followingcomponents:

* Summary of Impacts: The predicted negative environmental impacts for which mitigation is requiredshould be summarized.

* Description of mitigation measures: The EMP identifiesfeasible and cost effective mitigation measures to reduce significant negative environmental impacts toacceptable and legal levels. Mitigation measures shouldbe described in detail and be accompanied by designs,equipment descriptions, and operating procedures.

The technical aspects of implementing the mitigationmeasures should be described.

* Description of monitoring programme: Environmentalperformance monitoring should be designed to ensurethat mitigation measures are implemented. The monitoring programme should clearly indicate the linkages between impacts, indicators to be measured,measurement methods and definition of thresholds that will signal the need for corrective actions.

* Institutional arrangements: Responsibilities for mitigation and monitoring actions should be clearly defined.

* Legal enforceability: The key legal considerations withrespect to EMPs are:o Legal framework for environmental protection; ando Legal basis for mitigation.

* Implementation schedule and reporting procedures: The timing, frequency, and duration of mitigation Themeasures should be specified in an implementation schedule, showing links with the overall project.

Procedures to provide information on the progress andresults of mitigation and monitoring measures shouldalso be clearly specified.

* Cost estimates: Costs should be calculated for both the initial investment and recurring expenses for implementing the mitigation measures.

After the feasibility and design stages of the project, thoseprojects, which have significant negative impacts aresubjected to EIA. For projects of the type, which areundertaken frequently and which require authorisation,it may be advisable to develop the EMP as part of theEnvironmental Impact Report. This ensures that mitigation,monitoring and management considerations form part ofthe documentation used for decision-making. This hasthe benefit of giving the authority some assurance thatmitigation measures proposed during the EIA will beimplemented during the construction and operation phasesof the project.

The benefits of including the EMP as part of EIA (EIANewsletter, 1996) are:* encouraging applicants to be more systematic and

explicit in the design and development of mitigation measures and the intended means of implementation;

* encouraging authorities to check the practicality andlikelihood of implementation of mitigation and monitoring measures;

* ensuring that the mitigation measures are properly incorporated into the project design and contract documentation after authorisation is granted;

* encouraging the project proponent to meet the requirements of the EMP which now form the basis forthe conditions attached to authorisation of the project;

and* forcing the project proponent to internalise

environmental impacts that would otherwise becomea social cost.

Box 1 provides detailed information and guidance on the development of EMPs. The information provided in Box 1 canbe applied to developing an EMP for all phases in the project life cycle.

Box 1: Guidance for the formulation and implementation of EMPs

1. Obtain a comprehensive understanding of the activities and associated impacts of all the phases of the project. Appropriatemitigation and monitoring measures can then be implemented.2. Identify specific environmental risks and issues. This entails identifying the elements of the environment that need to beprotected as well as the range of activities that could possibly adversely affect them.3. Develop the suite of environmental controls and, ideally, prepare these as a set of specifications for integration into theconstruction tender or contract document. These environmental controls will include the mitigation measures, managementcontrols, and environmental standards to be met.4. When designing the EMP, questions to ask include:

* What is the scale of the construction and operational activities?* How sensitive is the receiving environment?* What are the potential environmental risks?

5. The mitigation measures must be practical and cost efficient so that they are readily implementable.6. Method statements are useful tools for the contractor to specify how mitigation actions will be implemented. Methodstatements describe:

* Construction and operational procedures;* Materials and equipment to be used;* How and where material will be stored;* Action to contain leaks or spills of any liquid or material;* The timing and location of construction and operational activities;

7. Identify and allocate roles and responsibilities for specific actions associated with mitigation, monitoring and performanceassessment.8. Establish a monitoring programme.9. Specify the mechanisms for achieving compliance (i.e. rewards and penalties).10. Develop an environmental awareness programme.

page 7


5. LEGAL ENFORCEABILITY OF ENVIRONMENTAL MANAGEMENT PLANS

In South Africa EMPs have increasingly become part of theconditions of approval for development. The projectproponent cannot delegate accountability for complianceto individual sub-contractors.

A good approach to facilitate legal enforceability of theEMP, is to integrate the EMP into the tender and contractdocument (between the proponent and sub-contractor)as a set of environmental specifications. The incorporationof environmental considerations into the tender andcontract documents is a fundamental prerequisite for theeffective implementation of the EMP (Barker and Hill,2000).

Using this approach the contractor thus has a clearunderstanding of the environmental requirements andassociated costs prior to being appointed.

To ensure compliance, it is essential that the environmentalspecifications are written in the same language style andformat as the rest of the contract document. The textfor the mitigation measures and environmentalspecifications has to be developed early in the process sothat it can be incorporated into the tender and contractdocuments. In cases where the environmental specificationsare developed after the tender has been awarded, it ismuch less likely that mitigation measures will beimplemented.

Enforcement is more readily achieved if the projectproponent has a clear understanding early in the contractingprocess of the actions and costs associated withenvironmental mitigation.

6. TYPES OF ENVIRONMENTAL MANAGEMENT PLANS

There are three broad categories of EMPs in the projectlifecycle: the construction EMP, the operations EMP andthe decommissioning EMP.

The objectives of these EMPs are all the same, namely to:

1. identify the possible environmental impacts of the proposed activity; and

2. develop measures to minimise, mitigate and managethese impacts.

The difference between these EMPs is related to thedifference in mitigation actions required for the differentstages of the project cycle.

6.1 The Construction Phase Environmental ManagementPlan

The construction phase EMP provides specific environmentalguidance for the implementation and construction phaseof a project. It is intended to enable the managementand mitigation of construction activities so thatenvironmental impacts are avoided or reduced. Theseimpacts range from those incurred during start up (e.g.site clearing, erection of the construction camp) toconstruction activities (i.e. erosion, pollution of

watercourses, noise, dust).

Information presented in the EMP is typically categorisedas follows:* identify the specific activity or potential impact that

requires management;* determine the mitigation measures to be implemented;* identify the performance indicator;* identify who would be responsible for implementation;

and* identify who would be responsible for monitoring.

6.2 The Operational Phase Environmental ManagementPlan

The operational phase EMP provides specific guidancerelated to the operational activities associated with aparticular development. The roles and responsibilities formitigation, monitoring and performance assessment forthe operational life of the development are specified inthe EMP.

6.3 The Decommissioning Phase Environmental Management Plan

As the final phase in the project cycle, decommissioningmay present positive environmental opportunities associatedwith the return of the land for alternative use and thecessation of impacts associated with operational activities.However, depending on the nature of the operationalactivity, the need to manage risks and potential residualimpacts may remain well after operations have ceased.Examples of potential residual impacts and risks includecontamination of soil and groundwater, stock that hasbeen abandoned (e.g. oil drums, scrap equipment, oldchemicals) and old (unserviceable) structures. Thedecommissioning phase EMP provides specific guidancewith respect to the management of the environmentalrisks associated with the decommissioning stage of aproject. The decommissioning phase EMPs are typicallyencountered within extractive industries such as mineralsmining and oil and gas exploration and extraction.

page 8

7. STRATEGIC ENVIRONMENTAL MANAGEMENT PLANS

Strategic Environmental Assessment (SEA) is commonlyreferred to as a process for assessing the environmentalconsequences of policies, plans and programmes (PPPs)(Sadler and Verheem, 1996). SEA has been identified asan appropriate instrument to incorporate environmentalaspects into strategic planning processes. It is not intendedthat SEA should replace EIA, rather SEA streamlines project-specific assessment by providing an effective instrumentfor environmental assessment at the plan and programmelevel. SEA may form the context for lower levels of planningand provide input into higher, more strategic levels (DEATand CSIR, 2000).

However, since SEA informs the EIA process, which in turninforms and guides the EMP, SEA establishes a sound basisfor mitigation, monitoring and management at a projectlevel (World Bank, 1999).

Figure 2: Hierarchy of environmental systems, showing the conceptual relationship between SEA; a StrategicEnvironmental Management Plan (SEMP); and Environmental Management Systems (adapted from CSIR, 1997)

An EMP that has been developed where a SEA frameworkexists should help to establish a sound planning andmanagement framework. This EMP is known as a StrategicEnvironmental Management Plan (SEMP). The SEMP providesthe framework for addressing cumulative impacts of ongoingdevelopments through a spatial approach to mitigation,monitoring and management (Figure 2). SEAs highlight key issues of concern in the sector or region,whilst SEMPs may prescribe standard approaches to projectdesign and mitigation through environmental guidelinesand monitoring requirements. This reduces the scope ofwork for individual EIAs and detailed EMPs for projects.

SEMPs have increasingly been used in South Africa toprovide management frameworks to guide development. The SEMP provides the means to incorporate environmentalobjectives into development decision-making processes.

SEASTRATEGIC

ENVIRONMENTALMANAGEMENT PLAN (SEMP)

* Criteria for project-level EIA* Roles and responsibilities for environmental

management* Cumulative impacts and sustainability indicators* Regional standards* Carrying capacity* Limits of acceptable change* Spatial development framework

PROJECT LEVEL EIA* Design guidelines* Detailed Environmental Management

Systems (EMS) based on ISO 14001

* Detailed mitigation and monitoring measures specified and implemented

* Feedback to higher levels

page 9


8. INTEGRATION OF THE EMP INTO OPERATIONS

The EMP should not become an additional requirementseparate from the day-to-day activities of the site. If theEMP becomes another layer of control the staff will seeit as an obstruction to normal duties and operations. Forthe EMP to be effective it must be part of a company’sroutine operations (EPA, 1995a).

Commitment from all levels of management and theworkforce is the most important element in the successof an EMP.

An EMP shifts the focus of operations and places a slightlydifferent emphasis on operations and on the role of manyindividuals. Employees are not only required to carry outtheir traditional duties, but must be able to identify andact to minimise or avoid environmental impacts (EPA,1995a).

Environmental requirements should be integrated intoexisting procedures, rather than becoming a new layer ofcontrol.

9. IMPLEMENTATION AND MONITORING

The key to the success of an EMP lies in its effectiveimplementation. Compliance monitoring is thereforecrucial. Monitoring ensures that the environmentalrequirements stipulated in the EMP are being compliedwith. It also allows for ongoing impacts to be tracked sothat the effectiveness of the mitigation can be measured(EIA Newsletter, 1996).

9.1 Developing a monitoring programme

Environmental monitoring provides the data for review,checking and revising the EMP. By instituting regularmonitoring, environmental impacts can be detected earlyand remedial action implemented (EPA, 1995b). Theprocess for establishing a monitoring programme consistsof the following actions:

* specify management objectives;* specify monitoring objectives;* identify the scope of monitoring;* recommend appropriate monitoring technology;* specify how the information collected should be used

in decision-making;* define the spatial boundaries and select map scales

and sites for observation, measurement or sampling;* select key indicators for direct measurement,

observation or sampling;* define how the data will be analysed and interpreted

and how it should be presented in monitoring reports;* define the precision and accuracy required in the data;* consider compatibility of data to be collected with

historical data and with related contemporary data; and

* set minimum requirements for monitoring.

The monitoring actions described above fits within theoverall process of developing the EMP, monitoringprogramme and performance assessment (Figure 3).

Figure 3: Framework process for developing the EMP and monitoring programme (adapted from EPA, 1995b)

GOAL OF THE EMP Demonstrate to authorities and stakeholders that activities comply with legislated environmental quality objectives and achieve good environmental performance.

STANDARDS Apply national standards for environmental management. Environmental systems shouldcomply with the international standards series ISO 14000.

MANAGEMENT * detect short and long term trends;OBJECTIVES * recognize environmental changes and analyse causes;

* measure impacts and compare with predicted impacts;* improve the monitoring system; and* improve practices and procedures for mitigation.

MONITORING

Specific monitoring requirements are developed in the process of preparing the EMP. They include* what to measure;* where to measure;* when to measure;* how to measure;* how often to measure;* methods to be used;* additional information required.

PERFORMANCE ASSESSMENT

* identify trends, causes and impacts;* assess performance and compliance;* modify practices and procedures for mitigation; and* modify monitoring programme.

page 10

Table 1: Example of a format for data collection and monitoring

ENVIRONMENTALCOMPONENT

Groundwater

Monitoring bore holes

Terrestrial Ecology

Rehabilitation: planestablishment

Rehabilitation: plantspecies diversity

Fauna

Feral animal control

Avifauna

MONITORINGFREQUENCY

Monthly

Six monthly

Survey re-vegetated areaevery six months

Survey plots oncea year

Six monthly

Inspect for feralanimals every twodays.

Survey bird pairsduring breedingand nestingperiods.

MONITORINGMETHOD

Water levels taken andtranslated to heightdatum. Flow rates andpump rates and flowmetre reading taken.

Samples taken for majorion analysis.

Density of seedlingsmeasured. Survey areaevery six months.

Record number ofindigenous plant speciesin selected plots

7 sites x 2 transects

Control feral animals bytrapping, baiting orshooting asrecommended byconservation authorities.

Record breeding, nestingand survival success.

DATA CAPTURE

Capture data inspreadsheet. Calculatesalinity. Trendsanalyses every month.

Capture data inspreadsheet. Trendsanalyses every sixmonths.

Capture data inspreadsheet. Usegraphs to illustratetrends.


Record species present.Capture data inspreadsheet. Use graphsto illustrate trends.

Areas where feralanimals have beentrapped or baited areinspected every twodays.


REMEDIALACTION

Remedial action asrequired.

Remedialaction as required.

If method ofcontrol is notsuccessful furthertrapping or baitingis carried out.

9.2 Monitoring and Data Collection

The monitoring programme should detect trends andchanges to enable intervention or remedial measures tobe taken in order to achieve good environmentalperformance. Within each environmental component orspecialist area (e.g. groundwater, terrestrial ecology andavifauna) there are appropriate techniques for collection,analysis and interpretation of data. The criteria that needto be employed for effective data collection, managementand reporting include:* realistic sampling programme (temporal, spatial and

point data);* collection of quality data;

* compatibility of new data with historical data;* cost effective data collection;* quality control in measurement and analysis;* appropriate databases to capture, store, retrieve and

display the data; and* reporting for internal management and external

auditing.

Ideally, the monitoring data should be presented in theform of maps, photographic records, data tables andgraphs. An example of a format for data collection andmonitoring is given in Table 1.

page 11


9.3 The Environmental Awareness Training

The workforce should undergo an environmental awarenesstraining course. This should be in addition to any specificdetailed training they may require to conduct monitoring. Environmental awareness training is critical for theworkforce to understand how they can play a role inachieving the objectives specified in the EMP.

9.4 Audits

Regular reviews of the company’s environmentalperformance are necessary during the operational phasesof a project to ensure procedures are appropriate, and toensure that environmental objectives and targets are beingachieved. The reviews should be regular and assess thecompany’s performance against legal standards and internalobjectives and targets (EPA, 1995a).

Environmental audits identify existing and potentialproblems on the environment, and determine what actionis needed to comply with legal requirements and internal.Further detailed information on environmental auditingis presented in the DEAT (2004c) publication onEnvironmental Auditing.

10. PUBLIC INVOLVEMENT IN EMPS

Generally, the public is not directly involved in thedevelopment of the EMP. Rather, public issues and concernsexpressed during the EIA process are incorporated intothe EMP. A way of eliciting public comment on the EMPis to present it in the Environmental Impact Report (EIR). At this early stage it would be difficult to present acomprehensive EMP. A “framework” EMP included as partof the EIR can highlight key environmental issues andidentify appropriate mechanisms to deal with these issues. It would allow members of the public an opportunity tocomment on the mitigation and monitoring specifications.

Usually there are no formal mechanisms for the public todetermine whether the environmental commitments inthe EMP are being met (World Bank, 1999), neverthelessthe public may still have an important role to play duringthe implementation of the EMP. Since many of theenvironmental controls are designed to mitigate potentialimpacts on neighbouring communities, the public mayprovide a specific monitoring role to ensure that they arenot being unduly affected by the proposed activitiesassociated with the particular project. An EnvironmentalMonitoring Committee (EMC) or Environmental LiaisonCommittee may be established to monitor progress andperformance.

Interaction between the community and the company isessential to build levels of confidence and trust.

11. CONCLUSIONS

The development and implementation of a successful EMPhas benefits beyond merely meeting legal obligations. Itcontributes to the environmental awareness of theworkforce. It can facilitate the prevention of environmentaldegradation, and minimise impacts when they areunavoidable.

Given the current focus on the assessment stage ofenvironmental impact assessment, EMPs add value todecision-making by demonstrating commitment toimplementation of mitigation actions.

An EMP can cover all company and site activities, fromconstruction to operation to decommissioning. An EMPcan ensure good environmental performance and improvecommunity relations. The EMP facilitates progress towardsenvironmental targets and provides a tool for continuousimprovement of a company’s environmental performance.The key to a successful EMP is commitment by all levelsof management and the workforce. The integration ofthe EMP into daily operations is crucial.

12. REFERENCES

Barker, G. and Hill, R. (2000) Partnerships in theconstruction industry – The practical implementation ofEnvironmental Management Plans, Proceedings of theIAIAsa Conference in Goudini, International Associationfor Impact Assessment – South African Affiliate, 22 – 33.

CSIR (1997) Strategic Environmental Assessment forthe Coega Industrial Development Zone, CSIR-Environmentek, Stellenbosch.

DEAT (2004a) Overview of Integrated EnvironmentalManagement, Integrated Environmental ManagementInformation Series 0, Department of Environmental Affairsand Tourism (DEAT), Pretoria.

DEAT (2004b) Environmental Auditing, IntegratedEnvironmental Management Information Series 14,Department of Environmental Affairs and Tourism (DEAT),Pretoria.

DEAT and CSIR (2000) Strategic Environmental Assessmentin South Africa: Guideline Document. Department ofEnvironmental Affairs and Tourism, Pretoria, South Africa.

EIA Newsletter (1996) Monitoring, EnvironmentalManagement Plans and Post-Project Analysis, EIA Centre,Department of Planning and Landscape, University ofManchester, Manchester.

EPA Australia (1995a) Environmental ManagementSystems, Best Practice Environmental Management inMining, Environment Protection Agency, Commonwealthof Australia.

EPA Australia (1995b) Environmental Monitoring andPerformance, Best Practice Environmental Managementin Mining, Environment Protection Agency, Commonwealthof Australia.

George, C. (2000) Environmental monitoring, managementand auditing, in: Lee, N. and George, C. (eds.),Environmental Assessment in Developing and TransitionalCountries: Principles, Methods and Practice, John Wileyand Sons, Chichester.

page 12

Ira, S.J.T., Reid, S. E., Spinks, A.C. and Blaine, L.A. (2000)Environmental Management Programmes for CivilEngineering Construction Activities, Proceedings of theIAIAsa Conference in Goudini, International Associationfor Impact Assessment – South African Affiliate, 164 – 175.

Mafune, I., Mclean, B., Rodkin, H. and Hill, R.C. (1997)The early years of EA in South Africa: A review of casestudies from 1971 to 1986, Proceedings of the IAIAsaConference in Pilanesberg Park, International Associationfor Impact Assessment – South African Affiliate, 199 - 204.

Parkes, L., Solomons, M., Spinks, A. and Luger, M. (2001)Are EMPs facilitating environmentally responsibledevelopment, or just window dressing? Proceedings ofthe IAIAsa Conference in White River, InternationalAssociation for Impact Assessment - South AfricanAffiliate, 223 - 224.

Sadler, B. and Verheem, R. (1996) Strategic EnvironmentalAssessment: Status, Challenges and Future Direction,MER Series, Ministry of Housing, Spatial Planning and theEnvironment, The Hague.

World Bank (1999) Environmental Management Plans,Environmental Assessment Sourcebook Update,November 25. Environment Department, World Bank,Washington D.C.

page 13


13. GLOSSARY

Definitions

Affected environmentThose parts of the socio-economic and biophysical environment impacted on by the development.

Affected publicGroups, organizations, and/or individuals who believe that an action might affect them.

Alternative proposalA possible course of action, in place of another, that would meet the same purpose and need. Alternative proposalscan refer to any of the following but are not necessarily limited thereto:* alternative sites for development* alternative projects for a particular site* alternative site layouts* alternative designs* alternative processes* alternative materialsIn IEM the so-called “no-go” alternative also requires investigation.

AuthoritiesThe national, provincial or local authorities, which have a decision-making role or interest in the proposal or activity.The term includes the lead authority as well as other authorities.

BaselineConditions that currently exist. Also called “existing conditions.”

Baseline informationInformation derived from data which:* Records the existing elements and trends in the environment; and* Records the characteristics of a given project proposal

Decision-makerThe person(s) entrusted with the responsibility for allocating resources or granting approval to a proposal.

Decision-makingThe sequence of steps, actions or procedures that result in decisions, at any stage of a proposal.

EnvironmentThe surroundings within which humans exist and that are made up of -i. the land, water and atmosphere of the earth;ii. micro-organisms, plant and animal life;iii. any part or combination of (i) and (ii) and the interrelationships among and between them; andiv. the physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health

and well-being. This includes the economic, cultural, historical, and political circumstances, conditions and objectsthat affect the existence and development of an individual, organism or group.

Environmental Assessment (EA)The generic term for all forms of environmental assessment for projects, plans, programmes or policies. This includesmethods/tools such as EIA, strategic environmental assessment, sustainability assessment and risk assessment.

Environmental consultantIndividuals or firms who act in an independent and unbiased manner to provide information for decision-making.

Environmental Impact Assessment (EIA)A public process, which is used to identify, predict and assess the potential environmental impacts of a proposed projecton the environment. The EIA is used to inform decision-making.

Fatal flawAny problem, issue or conflict (real or perceived) that could result in proposals being rejected or stopped.

ImpactThe positive or negative effects on human well-being and/or on the environment.

page 14

Integrated Environmental Management (IEM)A philosophy which prescribes a code of practice for ensuring that environmental considerations are fully integratedinto all stages of the development and decision-making process. The IEM philosophy (and principles) is interpreted asapplying to the planning, assessment, implementation and management of any proposal (project, plan, programme orpolicy) or activity - at the local, national and international level - that has a potentially significant effect on theenvironment. Implementation of this philosophy relies on the selection and application of appropriate tools to a particularproposal or activity. These may include environmental assessment tools (such as Strategic Environmental Assessmentand Risk Assessment); environmental management tools (such as monitoring, auditing and reporting) and decision-makingtools (such as multi-criteria decision-support systems or advisory councils).

Interested and affected parties (I&APs)Individuals, communities or groups, other than the proponent or the authorities, whose interests may be positively ornegatively affected by a proposal or activity and/or who are concerned with a proposal or activity and its consequences.These may include local communities, investors, business associations, trade unions, customers, consumers andenvironmental interest groups. The principle that environmental consultants and stakeholder engagement practitionersshould be independent and unbiased excludes these groups from being considered stakeholders.

Lead authorityThe environmental authority at the national, provincial or local level entrusted in terms of legislation, with theresponsibility for granting approval to a proposal or allocating resources and for directing or coordinating the assessmentof a proposal that affects a number of authorities.

MitigateThe implementation of practical measures to reduce adverse impacts.

Non-governmental organizations (NGOs)Voluntary environmental, social, labour or community organisations, charities or pressure groups.

ProponentAny individual, government department, authority, industry or association proposing an activity (e.g. project, programmeor policy).

ProposalThe development of a project, plan, programme or policy. Proposals can refer to new initiatives or extensions andrevisions to existing ones.

PublicOrdinary citizens who have diverse cultural, educational, political and socio-economic characteristics. The public is nota homogeneous and unified group of people with a set of agreed common interests and aims. There is no single public.There are a number of publics, some of whom may emerge at any time during the process depending on their particularconcerns and the issues involved.

Role-playersThe stakeholders who play a role in the environmental decision-making process. This role is determined by the levelof engagement and the objectives set at the outset of the process.

ScopingThe process of determining the spatial and temporal boundaries (i.e. extent) and key issues to be addressed in anenvironmental assessment. The main purpose of scoping is to focus the environmental assessment on a manageablenumber of important questions. Scoping should also ensure that only significant issues and reasonable alternatives areexamined.

ScreeningA decision-making process to determine whether or not a development proposal requires environmental assessment,and if so, what level of assessment is appropriate. Screening is initiated during the early stages of the development ofa proposal.

Significant/significanceSignificance can be differentiated into impact magnitude and impact significance. Impact magnitude is the measurablechange (i.e. intensity, duration and likelihood). Impact significance is the value placed on the change by differentaffected parties (i.e. level of significance and acceptability). It is an anthropocentric concept, which makes use ofvalue judgements and science-based criteria (i.e. biophysical, social and economic). Such judgement reflects thepolitical reality of impact assessment in which significance is translated into public acceptability of impacts.

page 15


StakeholdersA sub-group of the public whose interests may be positively or negatively affected by a proposal or activity and/or whoare concerned with a proposal or activity and its consequences. The term therefore includes the proponent, authorities(both the lead authority and other authorities) and all interested and affected parties (I&APs). The principle thatenvironmental consultants and stakeholder engagement practitioners should be independent and unbiased excludesthese groups from being considered stakeholders.

Stakeholder engagementThe process of engagement between stakeholders (the proponent, authorities and I&APs) during the planning, assessment,implementation and/or management of proposals or activities. The level of stakeholder engagement varies dependingon the nature of the proposal or activity as well as the level of commitment by stakeholders to the process. Stakeholderengagement can therefore be described by a spectrum or continuum of increasing levels of engagement in the decision-making process. The term is considered to be more appropriate than the term “public participation”.

Stakeholder engagement practitionerIndividuals or firms whose role it is to act as independent, objective facilitators, mediators, conciliators or arbitratorsin the stakeholder engagement process. The principle of independence and objectivity excludes stakeholder engagementpractitioners from being considered stakeholders.

page 16

ABBREVIATIONS

CBO Community-based Organization

EA Environmental Assessment

EIA Environmental Impact Assessment

EMP Environmental Management Plan

EMS Environmental Management Systems

I&AP Interested and Affected Party

IEM Integrated Environmental Management

NGO Non-governmental Organization

SEA Strategic Environmental Assessment

Department ofEnvironmental Affairs and Tourism

Private Bag X447, Pretoria, 0001, South Africa, www.deat.gov.za

KIC

CO

NC

EP

TU

AL

DE

SIG

N A

ND

BR

AN

DIN

G/0

82

33

2 2

56

7

Documents

Information series 12: environmental management plans